CCUL Headlines: Risk & Compliance

FinCEN adds guidance on COVID-19 related activity, BSA obligations

Wednesday, May 20, 2020   (0 Comments)
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This past week, FinCEN issued two new pieces of guidance relating to COVID-19 and Bank Secrecy Act (BSA) obligations.

The first notice contains information regarding reporting COVID-19 related criminal and suspicious activity and reminds financial institutions of certain BSA obligations. FinCEN intends to issue several more notices similar to this one in the coming weeks.

The advisory wants to remind financial institutions that in the SAR narrative, it should not include their challenges during the pandemic, and should only include COVID-19 when it is tied to suspicious activity only.

An advisory was also issued regarding medical scams during COVID-19. Examples of fraudulent medical services include claims related to purported vaccines or cures for COVID-19, claims related to products that purportedly disinfect homes or buildings, and the distribution of fraudulent or unauthorized at-home COVID-19 tests. The advisory also mentions scams relating to price gouging, hoarding of medical-related items, and non-delivery fraud of medical-related goods. Specific red flags can be found in the advisory.

FinCEN requests financial institutions reference this advisory in SAR field 2 (Filing Institution Note to FinCEN) and the narrative by including the following key term: “COVID19 FIN-2020-A002” and select SAR field 34(z) (Fraud-other).


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